Health Information Exchange Governance Valentine from Dr. Farzad!

Health Information Exchange Valentine


I listened in on this town hall this afternoon!


Happy Valentine’s day to me!


I did not expect Dr. Farzad Mostashari, the National Coordinator of ONC to wish me (and all participants) a happy Valentines day as he was flying on an airplane to a far-flung local.  He spoke quickly about how he “hearted” all the “listening” and open discussion going on involving health information exchange-especially around the issue of governance.  Since his plane was landing, he had to cut his remarks short so other ONC staff took the reins for a really robust and interactive webinar session on the issue.

A Rational & Non-Regulatory Approach to Health Information Exchange Governance


It was reassuring to hear the ONC staff verify that they are committed to a listening approach rather than a pure regulatory approach to health information exchange governance.   This is a real relief to those of us who are still wading through the HIPAA Omnibus Rules.  They emphasized that they are in a listening and “information collecting” mode at present and plan to continue this way.  The ONC has had other townhalls on this and other topics.

My opinion: The complexity and level of detail that would need to exist in regulations is overwhelming, and with Health Information Exchange being a fairly new creature, regulation is just not pratical at this time.  It would also chill implementation, adoption and participation!  Who wants to have to deal with even MORE regulations and the associated penalties and costs?

There were several main themes developed throughout this town hall meeting:

  1.  Information should securely and privately follow the patient.
  2.  Trust is key. Trust policies are HUGE.  Providers, organizations and patients need to trust in the exchange.
  3.  Meaningful patient relationships and engagement regarding use of HIE. (Like understanding what it IS!)
  4. How will patients be able to get their data?  There was an advocate on the call for patient mediated exchange.
  5.  Increasing interoperability is crucial.
  6. Costs need to decrease.follows patient and there is trust in the organizations that are handling the information.
  7. Adopting best practicies for exchange. 
  8. Whether HIE’s will agree to exchange information with one another or whether they will “hoard” the data, especially if there is a profit-based incentive for doing so.  There is currenly no requirement that this sharing occur.
  9. Crossing boundaries of current EHR vendors.
  10. Closing “digital divide” barriers to implementation and meaningful exchange.

The ONC  plans to monitor the exchange ecosystem and evaluate what activites are occuring and what problems or issues arise which may benefit from “national activity.”   The ONC is the entity to monitor and potentially come up with regulations if they were later required,

My opinion: If people can’t play nicely and fairly in the sandbox the ONC will be willing to regulate.  It seems like the equivalent to a mom hearing kids fighting outside over buckets and shovels and saying “Don’t MAKE me come out there!”

An aside…there does not seem to be a lot of love for EPIC.  They might the be the kid in the sandbox preventing others from digging in.  Just an undertone I got. (opinion)

HIPAA Components to Health Information Exchange Governance

Joy Pritts, the Nations Chief Privacy officer offered some comments on understanding how the new HIPAA Omnibus rules should be interpreted as they pertain to Health Information Exchange.  She suggested that by looking at the preamble to the final rule, one can find guidance about whether HIE’s will be considered business associates.  From my own reading, the analysis will depend on whether the HIE is “pushing” or “pulling” data.

Overall, the call was quite informative and a great way to spend Valentine’s Afternoon!




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